Customer Privacy Notice
Debt Advisory Services Scotland is directly authorised to provide debt advice to people living in Scotland.
We are responsible for the quality of the advice and services that we provide to you where those products are regulated by the FCA.
Our Fair Processing Notice explains how we use your personal data, describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the GDPR.
Why are we asking you to read this document?
During the course of dealing with us we will ask you to provide us with detailed personal information relating to your existing circumstances and your financial situation. (Your Information). We would like to explain to you what we will need to do with Your Information, and the various rights you have in relation to Your Information.
What do we mean by “Your Information”?
Your Information means any information describing or relating to you. Your Information may identify you directly, for example your name, address, date or birth, National Insurance number and the like. Your Information may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation debt advice, Your Information may include:
Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants.
The basis upon which our Firm will deal with Your Information
When we speak with you about your financial position we do so on the basis that a contract for the supply of services is in place between us. In order to perform that contract, and to arrange the products you require, we have the right to use Your Information for the purposes we set out below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Information provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from creditors relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Information to enable us to meet any responsibilities we may be required for wider compliance with any legal or regulatory obligation to which we might be subject. If this were to arise we would be processing Your Information in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Information
If you have parental responsibility for children under the age of 16 it is also very likely that we (and consequently your creditors) will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of debt solutions may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant for claims and fraud management.
Your Special Data and any Criminal Disclosures will be used by us in the same way as Your Information generally, as set out in this Customer Privacy Notice.
How do we collect Your Information?
We will collect and record Your Information from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to providing you with debt advice. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, creditors. If we use technology solutions to assist in the collection of Your Information, such as software that is able to verify your identity on-line or to access your credit status and/or bank account entries, then you will be required to provide your consent for us or our nominated processor to access your information in this manner, and details of how such software operates will be provided to you prior to the activation of the service.
What happens to Your Information when it is disclosed to us?
In the course of handling Your Information we will:
record and store Your Information in our paper files, mobile devices and on our computer systems (websites, email, hard drives, cloud facilities) and it will be accessed by employees and consultants within, or contractors engaged, by our Firm as necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
submit Your Information to your creditors, both in paper form and on-line, in order to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that your creditors may raise
input Your Information, along with full details of your assets and liabilities to our computer systems.
use Your Information for the purposes of responding to any queries you or your creditors may have in relation to any products you may take out, or to inform you of any developments in relation to those products of which we might become aware
Sharing and transferring Your Information
From time to time Your Information will be shared with or transferred to:
third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified.
in each case for the purposes set out in this customer privacy notice, i.e. to progress your enquiry and to provide you with our professional services.
Please note that this sharing of Your Information does not entitle such third parties to send you marketing or promotional messages: it is shared for the purpose of ensuring we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve Your Information being transferred outside of the European Economic Area.
Security and retention of Your Information
Your privacy is important to us and we will keep Your Information secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard against Your Information being accessed unlawfully or maliciously by a third party, accidentally lost, destroyed or damaged.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is sent to us.
Your Information will be retained by us either electronically or in paper format for a minimum of six years, or if longer than six years, the duration of this Firm’s relationship with you.
Your rights in relation to Your Information
request copies of Your Information that is under our control
ask us to further explain how we use Your Information
ask us to correct, delete* or require us to restrict or stop using Your Information (details as to the extent to which we can do this will be provided at the time of any such request)
ask us to send an electronic copy of Your Information to another organisation should you wish*
change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with our Firm in relation to the use of Your Information
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
The Data Protection Officer, Debt Advisory Services (Scotland) Limited, 3 Stewart Street, Milngavie, Glasgow, G62 6BW
Telephone 0141 956 4088
If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Information, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Information or Your Special Data/Criminal Disclosures you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.